Privacy Policy
Privacy Policy
This notice describes how Alphier Capital LLP (“Alphier”) uses personal data. It outlines Alphier’s data protection obligations and your data protection rights under the General Data Protection Regulation 2018 (“GDPR”).
Our policy is to protect your privacy and your personal information. This Privacy Policy sets out the information we collect from you in order for you to use our services, how we manage that data, and our reasons for holding it. We respect the confidentiality of your information and your right to privacy. We are bound by the General Data Protection Regulation and relevant laws and regulations.
From time to time we may update the Private Policy and will notify you of these changes by posting the updated terms on our website www.alphiercapital.com
Alphier Capital LLP is the data controller of your personal information, and this policy applies to the processing of activities by us.
Why Alphier needs to process personal data
Your Data are collected to effectively and properly manage your account(s) with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including;
to provide you with information, products or services that you request from us (including through our website) or which we feel may interest you, where you have consented to be contacted for such purposes;
to make our procedures more efficient, to implement security measures and to combat fraud and other crimes;
to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting and
If at any time you wish to be removed from marketing mailing lists or for any limits to be applied with respect to marketing materials received by you, please let us know. You can do this by e-mailing your Alphier relationship manager, data protection officer or any of the Alphier Partners. Contact details are available on our contact page.
Data collection
Alphier may collect data:
when you or an agent of yours contacts Alphier in relation to business and services offered;
when you complete documents or forms during the course of business with Alphier;
from Service Providers and other third parties that assist us in conducting business;
when you telephone Alphier; and
when you use the Alphier website or online services.
Data storage
Alphier stores your data on physical and electronic media. Data is safeguarded by Alphier and its Service Providers by maintaining physical and electronic security controls that are designed to comply with applicable legal standards.
The Data that is collected or held in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who works for us or for one of our Service Providers. In some cases, the laws of the destination country may not provide the same level of data protection as countries within the EEA. However, all Data wherever they are held by Alphier will be afforded a high level of protection against any unauthorised or accidental disclosure, access or deletion. By submitting your Data you agree to this transfer, storing or processing.
Unfortunately, the transmission of information via the internet is not completely secure. Although Alphier will do its best to protect your Data, we cannot guarantee the security of your Data transmitted electronically. Any such transmission is at your own risk.
Data sharing
Alphier uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes.
Alphier and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from Alphier and its Service Providers, including your Data. Alphier and its Service Providers will comply with these laws to the extent required.
Alphier will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.
Types of data that might be collected
During Alphier’s relationship with you Alphier will collect and process Data about you, including:
information which individuals and entities provide when contacting us (including through using this website) (such as their names, postal addresses, telephone numbers, identification documents and e-mail addresses);
corporate information;
details of services provided to you; and
where permitted or required by regulators or the law, special categories of personal information such as health information or information relating to criminal convictions or offences.
Data retention
Alphier will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.
It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Alphier will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.
Cookies
Alphier does use cookies on its website.
Your personal data is not currently collected by Alphier using cookies. Further details are available in our cookie policy.
Lawful basis for processing
Alphier assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. Given that Alphier is an FCA regulated firm, the majority of lawful basis for Alphier’s processing is to meet its obligations to the FCA (legal obligation basis) or to fulfil its obligations to you under contract (contract basis).
Other lawful basis may be used where Alphier assesses this is necessary and appropriate.
Data subject rights
You have the following rights, in certain circumstances, in relation to your personal information:
Right to access your personal information (in an easily readable form);
Right to rectify your personal information;
Right to restrict the use of your personal information (in certain specific circumstances);
Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the “right to be forgotten”) that applies in some contexts under the General Data Protection Regulation is not likely to be applicable to most, if not all, of the personal information you provide to Alphier, given the specific nature of the purposes for which Alphier uses the data, as described above;
Right to object to processing of your personal information (in certain specific circumstances);
Right to data portability (in certain specific circumstances);
Right to withdraw consent (in certain specific circumstances); and
Right to receive information regarding any entities we disclose your data to.
Where Alphier or its Service Provider(s) requires your personal information to comply with AML or other legal requirements, failure to provide this information means Alphier will not be able to accept you as a client or investor.
Alphier shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.
Changes to this notice
Alphier will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Alphier website (www.alphiercapital.com).
How to contact Alphier
Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.
If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Alphier has processed your personal data, please contact Alphier by writing to info@alphiercapital.com or by post at the following address:
Data Protection Officer
Alphier Capital LLP
24th Floor, The Shard
32 London Bridge Street
London SE1 9SG